This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 1 of 23

DISCUSSION POINTS

FOR THE

ABRWH’S WORK GROUP ON LANL

(Rev. 0)

(Last updated by ORAUT: April 6, 2012)

This document has been assembled by NIOSH as a follow-up to the Meeting of the Advisory 

Board’s Work Group on LANL on May 2, 2011 at the Cincinnati Airport Marriott Hotel. The 

primary purpose of that meeting was to discuss remaining issues from the prior Work Group 

meetings held on April 29, 2010 and November 3, 2010. Many of these issues originated from 

report SCA-TR-SEC2010-0004, SC&A’s Review of NIOSH’s Evaluation Report for Los Alamos 

National Laboratory Special Exposure Cohort Petition SEC-00109. NIOSH has conducted 

additional research regarding these issues and has assembled relevant information for the Work 

Group. This working document is offered as a resource to guide the topics of discussion at the 

upcoming meeting scheduled for May 2012.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 2 of 23

WORK GROUP ISSUE 1: LANL CAPABILITY TO MONITOR AND MEASURE 

MIXED FISSION AND ACTIVATION PRODUCTS BY 1976

WG ISSUE 1-A: NIOSH provided updated approach for handling MAP dose reconstruction 

based on ratios to Be-7. SC&A has questions on source data used in the model; is OK with 

methodology. NIOSH still needs to collect data which could be used for the model. NIOSH has 

not yet collected that data however, based on quarterly reports they believe sufficient data does 

exist. NIOSH will also investigate the stack sample system to determine whether the samples be 

used for ratio determination is representative of the workplace exposures. NIOSH will also 

investigate whether other workplace samples exist for comparison.

NIOSH RESPONSE TO WG ISSUE 1-A: 

An updated WBC database has been provided by LANL. See Table 1 in the response below to 

Issue 3-2 for a summary of available data for years 1975 through 2003.

NIOSH has reviewed additional archived data at LANL relating to air monitoring at LAMPF and 

believes that the ratios to Be-7 determined previously are a reasonable representation of 

workplace exposures. NIOSH does not believe that it is necessary for the air monitoring data 

used to determine these ratios to be representative of the quantities to which workers were 

exposed, only to the nuclide ratios, because bioassay results are used to determine quantities.

The data used to determine the ratios to Be-7 include short-lived nuclides, so it does not appear 

that hold-up tanks were used.

NIOSH also reviewed extensive gross alpha-beta data from LAMPF, which included surface 

contamination, air monitoring, and nasal smears.

WG ISSUE 1-B: SC&A concerned about use of reactor ratios for other, non-reactor, facilities 

where the ratios would no longer apply. NIOSH needs to obtain data from various types of 

facilities and determine whether methodology would apply.

NIOSH RESPONSE TO WG ISSUE 1-B: 

NIOSH agrees that the MFP ratios from OTIB 0054 would not apply to non-reactor facilities or in

cases where fission products may have been separated. NIOSH has not been able to locate 

sufficient data to determine nuclide ratios applicable to other facilities, such as CMR, where 

work campaigns involving separated fission products, for example Sr-90, may have occurred. 
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 3 of 23

NIOSH has however found a tremendous amount of RWPs, workplace monitoring, and nasal 

smear data throughout the applicable time period for locations such as CMR and has evidence 

that appropriate bioassay methods were generally available.

WG ISSUE 1-C: NIOSH provided extensive quarterly and monthly reports ranging from 75-91 

showing had a program to identify who needed bioassay and for what specific nuclides.

NIOSH RESPONSE TO WG ISSUE 1-C: 

No NIOSH response required.

WG ISSUE 1-D: SC&A will review materials that NIOSH compiled to determine whether 

program in place was effective in identifying significant hazards and individuals who needed 

bioassay (for Non-accelerator, non-reactor - MAP, MFP, exotics).

NIOSH RESPONSE TO WG ISSUE 1-D: 

No NIOSH response required.

WG ISSUE 1-E: NIOSH will do biased sampling of checklist (driven by exotics, MAP and 

MFP) and determine whether individuals identified to receive bioassay samples actually had 

bioassay samples taken. NIOSH will also determine whether ALL workers associated with these 

‘project’ driven bioassay sampling efforts did receive bioassay and if not determine approach 

for assigning dose. NIOSH will also review checklists to determine if workers were designated 

for bioassay (exotic, MAP and MFP) when a significant internal hazard existed (based on 

location and hazard type identified in other cells in the checklist).

NIOSH RESPONSE TO WG ISSUE 1-E:

The Excel spreadsheet titled “LANL-Issue-1-E” in the ABRWH\AB Document Review\LANL SEC00109\Documents for 5-2012 WGMtg folder shows the bioassay scheduling and samples 

provided based on isotopic exposure for 1977 and 1978. It should be noted that, in many 

cases, more samples are provided than are asked for because the checklists are snapshots in 

time when they were written. Checklists were required for new hires, re-hires, transfers, and 

film badge requests. Therefore, a person could be required to leave more samples after they 

entered a position.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 4 of 23

This issue was to address MFPs, MAPs and exotics explicitly on the checklists. Plutonium and 

uranium have been included for completeness. It can be seen that MAP and MFP samples were 

requested and left according to the checklist. Note the Cs-137 scans for TA-53 workers and 

MAP/MFP for TA-3 (CMR alpha wing is a part), TA-48 and TA-50 workers, the latter being 

highlighted in yellow. However, other radionuclides (e.g., neptunium, curium, actinium) are not 

specified. The reason for this (as stated in the Evaluation Report) is that plutonium bioassay 

and alpha monitoring were required and covered all alpha emitters because of their similarities 

with plutonium being limiting. A procedural statement (SRDB Ref ID 110067) from 1975 for 

CNC-4 backs this up and states the following in part:

It is often necessary to prepare x-ray powder diffraction samples containing a radioactive 

actinide element as a constituent of the compound under investigation. Such samples are 

estimated at <= 10 micrograms in total weight; the actinide usually amounts to 50% by 

weight of the compound. Among actinides so treated have been Ac-227, Pa-231, Pu-239, 

Am-243, and Cm-244. Samples of thorium, uranium, and neptunium have also been 

examined; however, their activity is not as intense and does not present such a serious 

hazard. However, for standardization of manipulation, all alpha emitters are treated in the 

same way. [Emphasis added]

All alpha activity was done in a glove box.

See document SRDB Ref ID 110064 data capture for examples of urine sample requests from 

1975-1979 in CMR beyond what is required on the checklists. 

Checklists obtained from the 2/29/2012 data capture are similar to the 1977-78 checklists in 

regard to the radionuclides requested and sampled. 

WG ISSUE 1-F: NIOSH provided listing of radionuclides monitored for at LAMPF/ LANCE. 

SC&A followed up on memo stating that ‘reference library’ was inadequate. SC&A was unable 

to contact original authors of the memo. SC&A and NIOSH will set up a conference call with 

internal dosimetry group at LANL to discuss the significance of this issue.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 5 of 23

NIOSH RESPONSE TO WG ISSUE 1-F: 

This issue originated with SC&A Report SCA-TR-SEC2010-0004, Review of Evaluation Report for

SEC-00109. In that report, SC&A made numerous references to a July 9, 2001 DOE audit report. 

In that audit report, there was an Observation (not a Finding) about the “Lack of Analytical 

Service Agreement” between the internal dosimetry organization and the in vivo laboratory.

The discussion included with that observation suggested that since LANSCE nuclides and 

thorium were not included in gamma spec libraries, or specifically looked for, that there may 

have been a lack of capability to monitor for those nuclides.

Per an email on February 19, 2012 from Joe Fitzgerald (SC&A) to Mark Griffon (Board 

Workgroup Chair for LANL) and Greg Macievic (DCAS): The internal dosimetry group declined to 

be interviewed, but agreed to written questions.

The written questions asked, along with the associated LANL responses, are attached to this 

document (Attachment A).

In summary, the LANL responses indicate that this observation regarding the reference libraries 

did not impact LANL’s capability to detect and quantify Th-232 or mixed activation products.

LANL indicated in its response that even presently, given the R&D nature of LANL radiological 

work, there may occupational exposures to secondary radionuclides that are not present in the 

reference libraries. However, this would not prevent measurement and assessment of dose 

from such secondary radionuclides. The trigger for reporting such secondary nuclides are 

“unidentified peaks” in report printouts. LANL provided current measurement procedures 

(SRDB Ref ID 84156) and procedures that were in place during the 2001 DOE assessment (SRDB

Ref ID 83663), both of which detail the policy for addressing unidentified peaks and assigning 

intakes for radionuclides not listed in the reference libraries.

WG ISSUE 1-G: NIOSH posted the requested documents. No further action.

No NIOSH response required.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 6 of 23

WORK GROUP ISSUE 2: NIOSH’S ASSUMPTION REGARDING INTAKE VALUES 

FOR EXOTIC RADIONUCLIDES AT LANL

WG ISSUE 2-1: SC&A questions completeness of table of exotics provided by NIOSH. 

NIOSH RESPONSE TO WG ISSUE 2-1: 

The internal dose bounding methodology listed in the Evaluation Report assigns intake values 

based on the co-worker intakes of ORAUT-OTIB-0062; the actual radionuclide presenting a 

potential exposure would be determined from case-specific information. The method provides 

enough flexibility to bound dose from any presumptive exposure to alpha-emitting 

radionuclides suggested by case data, so is not limited to those listed in the ‘exotic’ 

radionuclides table. It is also applicable to any era in which the dose reconstructor identifies a 

presumptive unmonitored exposure. 

Specifically, the following comments are offered:

a. Po-210 (verify only in early period; have bioassay in 2007-2008)

Unmonitored exposures are unlikely to occur in this era.

b. Ac-227 – was all complete by 1975? Was it used in other areas?

No additional usage was discovered; however any presumptive exposure identified in case 

data can be bounded using the method described above.

c. Bk-249 – OK as on NIOSH table

No specific response required.

d. Cf-252 – OK as on NIOSH table

No specific response required.

e. Cm-244 – later time? Other areas? Other Cm isotope? (document at DOE – “Alternative 

Nuclear Materials”)

Presumptive exposures identified in case data can be bounded using the method 

described above.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 7 of 23

f. Am-241/243 – table ok; see item e above for special classified project.

Presumptive exposures identified in case data can be bounded using the method 

described above.

g. Np-237 – source term issues exist beyond 1975 (classified issues – Sam Glover is aware of 

this)

Presumptive exposures identified in case data can be bounded using the method 

described above.

h. Thorium – post 75? Consider tiger team -mentions low quantities; should verify if just lab 

quantities post 1975. SRDB-066599 (Hanford document) discusses scrap with thorium 

sent to LANL in the 80s.

Presumptive exposures identified in case data can be bounded using the method 

described above.

i. Protactinium – table seems OK. Check time frames for presence in CMR.

Presumptive exposures identified in case data can be bounded using the method 

described above.

NIOSH will follow-up on available monitoring records for above nuclides (see Nov 11 2010 

action item). 

WG ISSUE 2-2: SC&A questions whether the exposure path for all other radionuclides is 

similar enough to plutonium to accept the use of plutonium as a surrogate for all other exotics 

(handling is analogous to plutonium -- controlled exposure to same level of rigor as plutonium). 

If this can be proven than NIOSH approach, using plutonium coworker data for intake and 

calculating dose based on exotic nuclide of concern, or worst case, would likely be acceptable. 

SC&A will provide more information on cases which might be exceptions that don’t fit into this 

approach (thorium, actinium, neptunium , curium (classified, see above).

NIOSH RESPONSE TO WG ISSUE 2-2: 

No NIOSH response required.

WG ISSUE 2-3: No action.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 8 of 23

WG ISSUE 2-4: NIOSH to provide a matrix (from checklist data, HP quarterly report data, 

RWP data) to look at which workers (job types) were monitored for which exotic radionuclides 

over time. SC&A will review documents provided by NIOSH.

NIOSH RESPONSE TO WG ISSUE 2-4: 

This issue is an adjunct to Issue 1-E above. This issue requests the review of SWPs, RWPs, 

quarterly reports, and checklists for exotics, MFPs and MAPs based on job types. Before 

proceeding to new information, we have provided documents from previous work group 

meetings in the ABRWH\AB Document Review\LANL SEC-00109\Documents for 5-2012 

WGMtg folder that have dealt with this issue. Here are two of those documents for further 

review: Quarterly Survey Report Data Excel file and Quarterly Survey Data Statistics Excel file. 

These two summary documents show the number of surveys performed at different facilities, 

some dosimetry, and incidents. 

As with Issue 1-E, the data capture does not produce documents that show actinide bioassay 

requirements. Nasal smears, alpha contamination surveys, and alpha spectrometry were used 

in the control of alpha emitters, regardless of nuclide. This, of course, did not mean that they 

were unaware of the types of radionuclides present. In the Quarterly Survey Report Data Excel

file also in the ABRWH\AB Document Review\LANL SEC-00109\Documents for 5-2012 WGMtg

folder, under the Important Talking Points tab, you will find parts of documents that exemplify 

this point. In particular, see Standard Operating Procedures for the Handling of Actinide 

elements. It has explicit discussion of the careful handling of actinides and states:

Although H-Division is responsible for routine air sampling and surface monitoring, CNC-4 

uses its own monitoring instruments. We check independently for alpha and gamma 

particularly during transfer operations.

This is a 1973 document. We have included several example documents that show the hazards 

associated with LANL facilities:

• See SRDB Ref ID 110062 for an example of Np-237 nasal smear data from CMR in 1984.

• See SRDB Ref ID 109554 for examples of special work permits from CMR. All jobs required 

at least a full face respirator and nose wipes checked for alpha contamination. 

• See SRDB Ref ID 107704 for chemical/radiological hazards for NMT-1 personnel. All the 

actinides are listed.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 9 of 23

• See SRDB Ref ID 109446 for example of experiments and calculations for Pu-242, Am and 

Np-237 experiments (unclassified information). 

• See CMR Building SM-29 Interim Safety Analysis Report Volume I, SRDB Ref ID 69340.

• See SRDB Ref ID 109556 for examples of gamma spectroscopy of CMR SM-29 stacks.

• See SRDB Ref ID 109450 for bioassay requirements for the Protection Force from 1981.

• See SRDB Ref ID 110063 for special work permits for C-14, Th, Hg-197, Tritium tritide (Pd), 

and Np-237.

• In the ABRWH\AB Document Review\LANL SEC-00109\Documents for 5-2012 WGMtg

folder, see the PDF document Mixed Waste Streams Characterized from 1992 for Actinide 

and Tritide Information.

WORK GROUP ISSUE 3: COMPLETENESS AND RELIABILITY OF LANL IN-VITRO 

AND IN-VIVO DATA, AND ADEQUACY OF NIOSH COWORKER MODEL (ORAUTOTIB-0062 AND ORAUT-OTIB-0063), POST 1975

WG ISSUE 3-1.1: NIOSH posted database. No further action

WG ISSUE 3-1.2: Remains a NIOSH action item.

NIOSH RESPONSE TO WG ISSUE 3-1.2: 

A revised in vivo bioassay database was received from LANL. There are additional results 

contained in this database, although there was not a significant increase in the totals.

However, this database demonstrates that not all nuclides are reported for every count. As 

previously discussed, database management of gamma spectroscopy results can become quite 

complicated because a large number of nuclides can potentially be detected in a single count, 

and not all are necessarily recorded, particularly if no activity is detected. Based on the 

database, we can add results to the coworker study by looking at the total number of body 

counts that were done in a year, and for counts where there’s no Cs-137 result reported, we 

can assume that it was <MDA. See the response to 3.2 for the total number of WBCs per year.

This should allow the coworker study to be reanalyzed, assessing each year individually rather 

than combining them into 5-year periods.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 10 of 23

WG ISSUE 3-2: Remains a NIOSH action item. 

NIOSH RESPONSE TO WG ISSUE 3-2: 

A review of the recently-received updated database indicates that, although there was a drop 

in the number of Cs-137 results per year reported after 1993, the total number of whole body 

counts per year did not drop on average. Table 1 summarizes the number of whole body 

counts reported in the database by year. Note that this does not include chest counts, which 

were performed primarily for plutonium and uranium. Because gamma spectroscopy is used 

for the measurements, there are a large number of potential nuclides that can be reported for 

each assessment. After 1993, Eu-152 was more likely to have been recorded for a given 

measurement in the database than was Cs-137. Nuclides reported most frequently include 

Be-7, C-11/N-13, Mn-54, and Na-22. Table 2 breaks out each year by reported nuclide. Several 

nuclides may be reported for a given measurement so the totals will not match those in 

Table 1.

Table 1: Total Reported Whole Body Counts Per Year

Year No. of WBC Year No. of WBC

1975 17 1990 66

1976 17 1991 71

1977 1 1992 88

1978 5 1993 120

1979 42 1994 72

1980 46 1995 57

1981 81 1996 64

1982 82 1997 62

1983 57 1998 67

1984 103 1999 70

1985 108 2000 108

1986 96 2001 75

1987 121 2002 89

1988 53 2003 66

1989 63

Table 2 (on the following three pages) shows the number of whole body counts per year by 

reported nuclides. Note that several nuclides may be reported for one count.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 11 of 23

Table 2: Number of Whole Body Counts Per Year by Reported Nuclides

Year

AS72BE7BI214BR76BR77 C11N13CD109CE141CO56CO57CO57

CO58

CO58CO60CR51CS134CS137CU64

1975 2 2 13 13 14

1976 8 8 1 5 4 4

1977 1 1 1

1978 3 4 2 2 2

1979 20 2 2 20 2 2 1 17 17 19

1980 20 2 2 20 2 2 15 13 16

1981 38 7 7 38 13 7 16 14 16

1982 3 51 12 12 50 12 12 1 4 1 13 14 14

1983 1 34 8 9 32 8 8 1 1 3 7 1 9 7 1

1984 1 59 8 8 61 8 8 2 1 4 6 2 8 6 2

1985 52 8 8 52 8 8 1 1 2 13 2 16 10 1

1986 5 51 3 3 51 3 3 5 31 34 32

1987 1 43 11 11 42 10 10 3 1 3 53 3 54 55 3

1988 2 28 5 5 28 5 5 2 13 14 14

1989 2 37 6 6 37 8 6 1 11 11 12

1990 52 1 1 52 2 1 12 12 13 1

1991 55 1 1 55 3 1 14 14 14

1992 65 1 1 65 4 1 19 18 19

1993 97 6 1 1 97 2 1 14 14 14

1994 64 2 2 64 2 2 3 3 3

1995 50 1 1 50 1 1 4 4 4

1996 51 1 1 62 1 1 1 1 1

1997 29 58 2 2

1998 27 1 1 58 1 1 9 7

1999 22 69 5 6

2000 1 105 3 3

2001 66 5 15

2002 74 13 21

2003 56 15 11
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 12 of 23

Table 2: Number of Whole Body Counts Per Year by Reported Nuclides (cont.)

Year

CU67EU152FE59FISSION 

PRODS

GE67

GA67

GE68

GA68

HF173HG195MHG197HG197MHG203I123I125I131 I-132MN54NA22

1975 1 2

1976 1 4 8

1977

1978 4

1979 2 2 2 2 2 20 7

1980 2 2 2 2 2 8 20 20

1981 13 7 13 7 13 17 38 38

1982 12 12 14 13 14 2 1 51 50

1983 1 8 1 8 10 8 9 7 2 34 32

1984 2 8 2 8 12 8 8 2 26 2 59 59

1985 1 8 1 1 2 8 8 8 8 39 1 55 52

1986 3 1 2 3 3 3 3 10 51 51

1987 3 10 3 2 2 10 10 10 10 21 42 43

1988 5 5 5 5 5 10 28 28

1989 8 6 8 6 8 8 1 37 37

1990 2 1 2 1 2 52 52

1991 2 1 2 1 2 55 55

1992 4 1 4 1 4 65 65

1993 2 1 2 1 2 2 97 97

1994 2 2 2 2 2 3 64 64

1995 1 1 1 1 1 2 50 50

1996 12 1 1 1 1 51 62

1997 28 2 29 57

1998 34 1 1 1 1 27 58

1999 47 1 22 69

2000 104 1 105

2001 66 66

2002 74 74

2003 56 56
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 13 of 23

Table 2: Number of Whole Body Counts Per Year by Reported Nuclides (cont.)

Year

NA24ND147OS185RB83RB84SB124SC46SE72

AS72

SE75SM145TA179TE132TL201TL202 V-48 ZN-65ZR95

1975 2

1976 8

1977

1978 3

1979 13 2 2 2 2 2 2 2 2 2 2

1980 2 2 2 2 2 2 2 2 2 2

1981 7 7 7 7 7 7 7 13 7 7

1982 12 13 12 12 12 4 12 12 12 12 14 1

1983 8 9 8 8 8 2 8 8 8 8 8 1 1

1984 8 8 8 8 8 1 8 8 8 8 8 3 2

1985 8 8 8 8 12 1 9 8 8 8 8 1 2 2

1986 3 3 4 4 3 5 1 4 3 3 3 3 1

1987 10 10 11 11 10 1 2 13 11 10 10 10 3 4

1988 5 5 7 5 5 2 1 11 5 5 5 5

1989 6 6 6 6 6 1 6 6 8 1 6 6 1

1990 1 1 1 1 1 1 1 3 1 1 1

1991 1 1 1 1 1 1 1 2 1 1

1992 1 1 1 1 1 1 1 4 1 1

1993 1 1 1 1 1 1 1 2 1 1

1994 2 2 2 2 2 2 2 2 2 2

1995 1 1 1 1 1 1 1 1 1 1

1996 1 1 1 1 1 1 1 1 1 1

1997

1998 1 1 1 1 1 1 1 1 1 1

1999

2000

2001

2002

2003
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 14 of 23

WORK GROUP ISSUE 4: FEASIBILITY OF DOSE ESTIMATION FOR NEUTRON 

EXPOSURE AT LANL, POST 1975

WG ISSUE 4-1: NIOSH provided proposed method for using ratios from 80-82 to extrapolate 

back to 76-79. NIOSH needs to follow-up on site data based on jobs and areas to assure 

operational documents support approach. If operational data supports NIOSH intends on using 

a distribution of n/p ratios for estimating neutron doses from 76-79.

NIOSH RESPONSE TO WG ISSUE 4-1: 

This issue pertains to taking NP ratio distributions from 1980-1982 and using them for the 

period 1976-1979. We could find no information to show that significant operational variations 

occurred during the period 1976 to 1982. Information previously sent to the work group 

showed that any changes in manpower and increase of dosimetry records began with the 

mid-1980s and would not be part of this extrapolation. In the ABRWH\AB Document 

Review\LANL SEC-00109\Documents for 5-2012 WGMtg file, we have included an Excel

spreadsheet, ISSUE 4-1, based on NOCTS data base job titles and descriptions cross-referenced 

to neutron and photon dose and NP ratio. It shows NP ratios to be in the range of the NP ratio 

distribution sent to the work group in previous meetings. We will also send to the work group a

new white paper entitled LANL Neutron-to-Photon (NP) Dose Ratio Analysis that discusses the 

NP ratio over time based on instrument measurements. This document is currently under 

classification review by LANL. There are several neutron/photon survey documents from the 

2/29/2012 data capture that pertain to LAMPF, where a large percentage of the neutron dose is 

received. These are: SRDB Ref IDs 109442, 109441, 45498, 109565, and 109579. In none of 

these documents is there information that contradicts the use of 80-82 NP ratio data for use in 

the years 1976-79.

Based on these data, we feel the extrapolation approach is valid and should be used. 

WG ISSUE 4-2: SC&A will review provided documents from NIOSH. SC&A generally OK with 

approach.

NIOSH RESPONSE TO WG ISSUE 4-2:

No NIOSH response required.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 15 of 23

WORK GROUP ISSUE 5: FEASIBILITY OF DOSE ESTIMATION FOR 

RADIOLOGICAL EXPOSURE SOURCES AT LAMPF/LANSCE (EXPOSURE TO 

WORKERS ADJACENT TO THE FACILITY)

WG ISSUE 5-1: LAMPF and LANCE examples considered as part of response to issue 4 –

include in distribution.

NIOSH RESPONSE TO WG ISSUE 5-1:

No NIOSH response required.

WG ISSUE 5-2: Remains a NIOSH action item

NIOSH RESPONSE TO WG ISSUE 5-2:

This issue pertains to LAMPF holding pond data and the ability to bound dose. Several 

documents were collected from LANL in the 2/29/2012 data capture pertaining to LAMPF 

lagoon survey data. LANL staff was contacted about the lagoon sampling and they stated that 

there are sufficient sampling data available for our needs; this was confirmed during the data 

capture visit. The following documents show examples from the mid-1980s of non-tritium 

radionuclides: SRDB Ref IDs 45509, 109619, 109613, 109621, 109622, 109624, 73424, 109620, 

and 45421. There are several more documents like this at LANL from other years, but the data 

contained in these files can be used to produce an estimate of dose. Specific to tritium, a PDF 

on 1986 tritium concentrations is provided in the ABRWH\AB Document Review\LANL SEC00109\Documents for 5-2012 WGMtg folder. It is entitled TA 53 Lagoon Tritium Concentration 

Plot 1986.

A model can be constructed from these data to bound dose from the east and west over-flow 

lagoons. 
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 16 of 23

WORK GROUP ISSUE 6: RADIATION EXPOSURE TO SPECIAL TRITIUM 

COMPOUNDS

WG ISSUE 6-1: NIOSH will have to get into the classified documents further to better 

characterize the source term and potential for exposure (who could be exposed and to what).

NIOSH RESPONSE TO WG ISSUE 6-1: 

NIOSH has reviewed the classified documents and has found nothing to alter the previous 

response to this issue.

WG ISSUE 6-2: Remains a NIOSH action item. SC&A is recommending that NIOSH consider 

two classified documents at Germantown related to this issue that should be considered (LANL 

related documents).

NIOSH RESPONSE TO WG ISSUE 6-2: 

NIOSH has reviewed the classified documents and has found nothing to alter the previous 

response to this issue.

WORK GROUP ISSUE 7: UNMONITORED EXPOSURE OF SUPPORT SERVICE 

PERSONNEL

No 05-02-11 issues listed for this item.

PETITIONER ISSUES RAISED DURING WORK GROUP MEETINGS

PETITIONER ISSUE 1.2: NIOSH will specifically address firing site in table of exotic 

exposures.

NIOSH RESPONSE TO PETITIONER ISSUE 1.2:

NIOSH acknowledges the firing site as a location where contamination may be present, 

including exotics contamination, and presumptive exposures to the so-called ‘exotic’ 

radionuclide may be addressed using the bounding internal dose estimate described in the 

Evaluation Report. This method assigns intakes based on co-worker intakes, leaving the 
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 17 of 23

radionuclide of concern and the era of possible exposure to be determined based on casespecific data.

PETITIONER ISSUE 1.3: NIOSH will not use badge access to determine dose. No further 

action.

PETITIONER ISSUE 1.4: No further action.

PETITIONER ISSUE 1.5: SC&A provided a response and NIOSH is considering SC&A 

response. Many are just clarifying questions. Two bigger issues: 1) adequacy of stack 

monitoring to estimate environmental doses and 2) resuspension from contamination should be 

further clarified (particularly of concern for support service workers).

NIOSH RESPONSE TO PETITIONER ISSUE 1.5:

For the purpose of bounding dose, if intakes are based on bioassay, even surrogate bioassay, 

the adequacy of stack monitoring or the issue of resuspension would be irrelevant.

PETITIONER ISSUE 1.6: NIOSH will address this in addressing the completeness of table on 

exotic source terms. Other areas which are of concern should be demonstrated to be covered by 

environmental exposure approach (see 1.5 of this section).

NIOSH RESPONSE TO PETITIONER ISSUE 1.6:

No NIOSH response required. See Issue 2-1.

PETITIONER ISSUE 1.7: NIOSH issued a white paper regarding approach for reconstructing 

doses to workers involved in fire. Doses based on available monitoring data as calculated by 

NIOSH were small. SC&A raised concerns about work by fire fighters in ‘up close operations’ 

where re-suspension might be an issue.

NIOSH RESPONSE TO PETITIONER ISSUE 1.7:

For particle sizes in the range of dosimetric interest (1-5 microns), settling velocities are low 

over the entire range (for wildland fire research, PM10 are considered as a group). Thus, 

concentrations would not vary significantly between sampling height (approximately 48-66 

inches) and closer to the ground. Larger, non-respirable, particle concentrations might vary 
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 18 of 23

more in this region; however, studies of wildland fire smoke and particulate do not furnish 

detail on this issue. Similarly, low settling velocities also mean that samplers near the fire are 

likely to be representative, for particles in the range of interest. Since some samplers were 

close enough for clogging to be an issue, AND the highest concentrations were used, the 

method used in the white paper is both unrealistic and overestimating. AIRNET stations 

actually do measure resuspended dust (Reference SRDB Ref ID 35741, page 94) at all times.

PETITIONER ISSUE 1.8: Remains an action for workgroup members.

NIOSH RESPONSE TO PETITIONER ISSUE 1.8:

Even though LANL work has often been campaign-based like work at NTS, there are significant 

differences between the two sites when considering the quantity and quality of available data. 

The health physics program at LANL appears to have been considerably more robust during this 

time period. It is certainly is documented much better. NIOSH therefore believes the LANL site 

should be evaluated separately based on its own health physics and dose assessment programs. 

REFERENCES

• LANL (Los Alamos National Laboratory) 1994. Los Alamos National Laboratory Environment, 

Safety and Health Division Personnel Dosimetry Operations – External Dosimetry Technical 

Basis Document, ESH-4-PDO-94:005. Los Alamos National Laboratory, Los Alamos, New 

Mexico. February 8, 1994. [SRDB Ref ID: 27265]

• LANL (Los Alamos National Laboratory) 2001a. Photodosimetry Evaluation Book, Volume 

VIII. Los Alamos National Laboratory, Los Alamos, New Mexico. [SRDB Ref ID: 27292]

• LANL SEC-00109. 2008. SEC Petition for all service support workers working in any Technical 

Area with a history of radioactive material at the LANL from 1976–2005. National Institute 

for Occupational Safety and Health, Office of Compensation Analysis and Support, 

Cincinnati, Ohio. May 29, 2008.

• Mallett, M.W., Vasilik, D.G., Littlejohn, G.J., and Cortez, J.R. 1990. High-Energy Neutron 

Dosimetry at the Clinton P. Anderson Meson Physics Facility, LA-11740-MS. University of 
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 19 of 23

California, Los Alamos National Laboratory, Los Alamos, New Mexico. January 1990. [SRDB 

Ref ID: 912]

• NIOSH (National Institute for Occupational Safety and Health) 2009. SEC Petition Evaluation 

Report, Petition SEC-00109, Rev 0. Office of Compensation Analysis and Support, Cincinnati, 

Ohio. January 22, 2009.

• ORAUT (Oak Ridge Associated Universities Team) 2007a. Fission and Activation Product 

Assignment for Internal Dose-Related Gross Beta and Gross Gamma Analyses, ORAUT-OTIB0054, Rev. 00. ORAUT, Cincinnati, Ohio. November 19, 2007.

• ORAUT (Oak Ridge Associated Universities Team) 2007b. Technical Information Bulletin: 

Internal Dosimetry Coworker Data for Los Alamos National Laboratory, ORAUT-OTIB-0062, 

Rev. 00-C. ORAUT, Cincinnati, Ohio. April 18, 2007.

• ORAUT (Oak Ridge Associated Universities Team) 2009b. Technical Basis Document for the 

Los Alamos National Laboratory – Occupational Internal Dose, ORAUT-TKBS-0010-5, 

Rev. 01-F. ORAUT, Cincinnati, Ohio. June 16, 2009.

• ORAUT (Oak Ridge Associated Universities Team) 2009c. Technical Basis Document for the 

Los Alamos National Laboratory – Occupational External Dose, ORAUT-TKBS-0010-6, Rev. 01 

PC-1-A. ORAUT, Cincinnati, Ohio. June 11, 2009.

• ORAUT (Oak Ridge Associated Universities Team) 2012. White Paper: LANL Neutron-toPhoton (NP) Dose Ratio Analysis, Rev. 00, ORAUT, Cincinnati, Ohio. March 15, 2012. 

(Document currently under LANL review)
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 20 of 23

ATTACHMENT A: LANL INTERVIEW RESPONSES

SC&A Site Expert Interview Questions & Responses

Los Alamos National Laboratory (LANL) Whole Body Counting/Assessment Staff

September 12, 2011; SRDB Ref ID: 110383 [reformatted]

Following are collective responses by knowledgeable staff from the LANL Radiation Protection 

Program, corresponding to Advisory Board questions received by LANL on August 23, 2011.

Question 1: Does the LANL ES&H, health physics, internal dosimetry, or in vivo program have 

any record of this audit and/or the LANL program’s response? If a written response is located, 

please provide a copy of it and any additional documentation pertaining to it.

LANL RESPONSE: Yes, LANL has a copy of the assessment mentioned above and a copy of the 

LANL response [August 2, 2001; ESH-RPO:01-21; “Response to DOE-LAAO Report Number 

2000-RP-1...”; Joseph Graf to Kenneth Zamora] (Attachments 1 & 2). This response 

documented corrective actions addressing Finding #1 of the assessment regarding 

management review of dosimetry enrollment. There is no additional documentation 

pertaining to this response available. Per instructions in the assessment report and 

convention at the time, there was no formal response to observations (opportunities for 

improvement) in the assessment report.

Question 2: Is there anyone on staff who is familiar with this review, its findings, or LANL’s 

response? If so, we would appreciate both a brief summary of what is known and an 

opportunity to discuss it with them. Likewise, if anyone is familiar with the issue of 

completeness of library reference peaks and how incomplete references may have affected 

LANL’s historic in vivo counting program, we would like to talk with them.

LANL RESPONSE: Yes, there is current LANL staff familiar with the topics discussed in the 

assessment. Observation #2 was an opportunity for improvement regarding procedural 

formality and adding analysis libraries for the LANL In Vivo Measurements Laboratory. As is 

well documented, the internal dosimetry program at LANL was focused on primary nuclides 

of concern, which is still true presently. IVML analysis libraries have been added over time 

as warranted based on potential occupational exposures; these libraries improve the process 

efficiency for identifying and quantifying nuclides. Without these libraries, the IVML 

instrumentation was - and remains - capable of detecting nuclides outside these libraries. 

The process in place still enabled identification and quantification of intakes of other 

nuclides – this was just done manually (see response to Question 5). Observation #2 

highlighted Th-232 and mixed activation products – both of these were detectable with 
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 21 of 23

IVML instrumentation in 2001 and before that; the observation merely pointed out 

opportunities to improve formality and business efficiency.

Question 3: How significant is this finding in terms of the LANL’s in vivo counting program being 

able to detect and report radiation exposures for LANSCE releases and for thorium in the 

workplace? The DOE audit indicated that LANL had not maintained its capability to routinely 

monitor mixed activation products from LANSCE and thorium. Did lack of library references 

impair detection and reporting in any way?

LANL RESPONSE: Observation #2 documented opportunities to improve formality and 

business efficiency. As stated in the response to Question 2, IVML had the capability to 

detect and quantify intakes of thorium and mixed activation products. The germanium 

detector system was operational and capable of detecting thorium intakes – the suggested 

improvement was to update procedures. Likewise, the IVML system was capable of 

detecting and quantifying mixed activation products – additional libraries would ease 

reliance on the manual process that was well-established. 

Question 4: What corrective actions were implemented in the internal dosimetry and/or in vivo 

program following the identification of deficiencies in the July 9, 2001 programmatic 

assessment?

LANL RESPONSE: Per instructions in the assessment report, LANL was obligated to respond 

to findings (deficiencies), not observations (opportunities for improvement). The memo 

referenced in Question 1 contained corrective actions responsive to Finding #1 of the 

assessment. We were unable to locate a LANL response corresponding to Finding #2 

regarding closure of previous radiobioassay issues by the Chemistry Division. 

Question 5: How are determinations made regarding what library references are maintained 

for various LANL sources, particularly the secondary ones that are either rarely measured or not 

radiologically as significant as Pu, Am, tritium, etc. What would trigger the in vivo program’s 

reporting of such secondary radionuclides? What is the written policy for identification and 

quantification of results from unidentified peaks in spectra?

LANL RESPONSE: Worker dosimetry is assigned based on the potential for occupational 

exposure using a process and system using location and activity-specific thresholds. The 

LANL Radiation Protection Program maintains internal (and external) dosimetry programs 

corresponding to these potential exposures. As indicated previously, LANL has added 

analysis libraries for the IVML counting systems over time, commensurate with these 

potential occupational exposures, to streamline the process of IVML measurements. Even 
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 22 of 23

presently, given the R&D nature of radiological work at LANL, there may be an occupational 

exposure to some nuclide not explicity in an IVML analysis library. This would not prevent 

the detection, investigation, identification, quantification, and assessment of dose from such 

a secondary radionuclide.

The trigger for reporting such secondary nuclides is the instance of “unidentified peaks” in 

IVML measurement report printouts, as described in detail in the following procedures: 

Attachment 3 is procedure ESH4-IVML-DP-37, R1, Performing Measurements and Analyses 

with SB-14 IVML Detectors (in place during the 2001 DOE assessment). Section 7.1.2 

Analysis clearly prescribes the capability and process for identifying and quantifying 

unidentified peaks in IVML measurement spectra.

Attachment 4 is procedure RP2-ID-DP-12.IVML, R1 Performing Measurements with IVML 

Counting Systems (Current procedure). Section 8.2 and Attachments 1 & 2 from that 

procedure clearly prescribe the capability and process for identifying and quantifying 

unidentified peaks in IVML measurement spectra. This approach remains essentially 

consistent with the earlier procedure and the process that has been applied since 

establishing this capability at LANL.

Question 6. What calibration sources are/have been used to calibrate in vivo detectors?

LANL RESPONSE: Attachment 5 is a list of Radioactive Sealed Sources used currently and 

historically at IVML. On this list are sources dating back to the 1970s, including two broadspectrum, mixed gamma sources from 1975 and 1977. These are indicators of the capability 

for identification of photon emitters of widely varying energies, enabling the detection of 

unidentified peaks discussed in the response to Question 5.
This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

Page 23 of 23

REFERENCES FOR ATTACHMENT A:

Attachment 1: Response to DOE-LAAO Report Number 2000-RP-1, Programmatic Assessment 

of the Internal Dosimetry Program at Los Alamos National Laboratory; SRDB Ref ID: 84156

Attachment 2: Programmatic Assessment of the Internal Dosimetry Program at Los Alamos 

National Laboratory; SRDB Ref ID: 83663

Attachment 3: Performing Measurements and Analyses with SB-14 IVML Detectors; Procedure 

ESH4-IVML-DP-37, R1; SRDB Ref ID: 110379

Attachment 4: Performing Measurements with IVML Counting Systems; RP2-ID-DP-12.IVML, 

R1; SRDB Ref ID: 110381

Attachment 5: IVML Exempt Radioactive Source Inventory; SRDB Ref ID: 110382